In this Corporate Policy, the term “Personal Information” means information in any form as interpreted by applicable privacy laws about an identified individual or an individual whose identity may be inferred or determined from such information.

Please note that you are not required to provide Personal Information to simply browse our Website. Only aggregated or anonymized information using cookies or other tracking technologies is provided to us (only if your browser or device has been set to allow such collection). We collect Personal Information when you choose to communicate it to us and do not need or collect sensitive Personal Information (e.g., financial information, health and medical conditions, race/ethnic origins) in the context of this Corporate Policy. Therefore, we ask you not to provide any sensitive Personal Information to us. Sensitive Information would only be required in exceptional circumstances, and in those circumstances, we will obtain your express consent.

We have implemented commercially reasonable administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information. For example:

• We have designated a Chief Privacy Officer who oversees Lucilab’s compliance with this Corporate Policy and applicable privacy laws;
• Access to your Personal Information by our employees is strictly limited to those who need to access it to perform their roles. Those within Lucilab who can access your Personal Information are the information technology department if there are technical issues, the research department if you have made inquiries regarding Lucilab’s research activities, the human resources department if you have applied for a position with us as well as the marketing and administrative departments to answer any questions you may have, to inform you of upcoming research projects (if you have opted in to participate in such projects) or to send you the newsletters to which you have subscribed;
• We follow industry standards on information security management to safeguard Personal Information; and
• We take measures to safeguard your Personal Information when sending it to our service providers. For example, we: (a) transfer only the Personal Information they need to perform their duties as described in Section 4 below; (b) enter into written contracts which bind them to obligations of confidentiality; and (c) de-identify the Personal Information when we are able to do so.

Unfortunately, no method of storage or transmission over the Internet can be 100% secure so, like all companies, neither we nor our suppliers can guarantee that your Personal Information is completely secure. Your cooperation is required to mitigate risks related to your Personal Information. If you become aware of any incident or breach in relation to your Personal Information, please contact us immediately.

Lucilab only collects Personal Information that is necessary for the purposes for which it is collected. If you are one of our customers using Luci App, please see the Luci App Privacy Policy for details about information that is collected, used and/or otherwise processed through the Luci App.

You are not required to provide any Personal Information to browse our Website. However, you may choose to do so or we may be required or permitted to collect Personal Information in accordance with applicable laws, as described below.

• Identification information and email address: We may collect your email address and the first and last name you submit when you choose to sign up to receive our Luci Newsletter, updates on the Luci App and other communications from us. We may also be able to see whether you have opened the communications – this information allows us to ensure that our communications remain relevant and customized to you.
• Identification information, email, phone number and date of birth: Such information may be collected if you wish to participate in our research studies. For example, date of birth is required as there is an age restriction to participate in the research studies.
• Employment related information: If you apply for a job at Lucilab, you may provide us with certain Personal Information about yourself (e.g., information contained in a resume, cover letter, or similar employment-related materials). We will use this information for the purpose of processing and responding to your application for current and future career opportunities.
• Other Personal Information voluntarily provided by you: Whether by phone, email, in person or message sent through our Website, we may collect your first and last name, email address, subject line and any other information you provide. We may retain this information for identification purposes, to answer the question or request you may have asked us, or to assist you in the future.
• Other information legally required or permitted by applicable laws or with your consent: Other Personal Information may be collected or obtained: (a) to protect our interests; (b) to enforce our policies; (c) to comply with legal and regulatory requirements; and (d) as otherwise permitted pursuant to applicable laws or as otherwise authorized by you.

Though generally not considered “Personal Information”, please note that we or our service providers may collect online browsing information in the form of aggregated or anonymized data if your browser or device is set to allow such collection. Please see below for more information.

Except as listed below, our policy is that we will not sell, rent, share, or authorize any third party to use your Personal Information without your consent. We also prohibit our service providers from using Personal Information other than for the specific purposes for which we provide it to them. These third-party providers only receive the Personal Information they need for the performance of any contract we enter into with them.

Below is a summary of why we may transfer or disclose Personal Information.

• To obtain services to fulfill the purposes for collection: We use third parties to collect and process Personal Information on our behalf. For example, we may use service providers to help us with a variety of services including recruiting and hiring efforts, sending our communications, IT and system administration, support and hosting, cloud storage, research, customer service, analytics, marketing, or audits.
• To reorganize, restructure or change the ownership or control of our company (purchase, transfer, or sale of services or assets): We may disclose Personal Information to third parties such as purchasers or financing companies in connection with a merger, acquisition or sale of all or a portion of our assets or other similar transaction.
• To comply with applicable laws, to respond to requests by government agencies or to protect our, your or others’ property, safety or other interests: We may share your Personal Information to courts and law enforcement, regulatory or other authorities in Canada or authorities in other jurisdictions if we are required to do so or if we believe it is necessary to protect us against potential liability, investigate and defend against claims or allegations, investigate and protect against fraud, protect the security and integrity of our Websites, ensure compliance with our policies, including this Corporate Policy, and protect the rights and property of Lucilab and others.

As mentioned above, we may disclose your Personal Information for other purposes with your consent or if permitted or required by law. If you have any questions or would like more details about our service providers or any other third parties, and the information we provide to them, please contact us.

Unless specified otherwise in this Corporate Policy, we will delete Personal Information we have under our control in the following circumstances:

• The purpose for which the Personal Information has been collected/obtained has been fulfilled, can no longer be achieved or the Personal Information is no longer necessary for the original purpose;
• Consent has been withdrawn; or
• Applicable laws, ethical requirements and/or contractual obligations do not permit the contemplated processing.

Where one of the above circumstances arise, your Personal Information will be destroyed, deleted, or made anonymous. After deleting your Personal Information, we may retain non-personally identifiable information and may continue to use it as permitted by this Corporate Policy and in accordance with applicable laws.

You may always request, as specified in the following section, that your Personal Information be deleted, but please note that we and our suppliers may be required to retain some of this information to comply with our legal obligations (in which case, we will comply with your request to delete the information only after we have fulfilled such obligations).

Applicable laws provide you with certain rights and choices with respect to your Personal Information as set out below. Please contact us if:

• you wish to know how your Personal Information is collected, used or otherwise handled;
• you wish to access, update, correct or request deletion of your Personal Information;
• you wish to withdraw your consent to the processing of your Personal Information, or to restrict or object to our processing of your Personal Information;
• you wish to know whether automated decision making is used or to challenge any such decision;
• you wish to request a copy of your Personal Information that we process;
• you have a question or complaint about this Corporate Policy or the manner in which your Personal Information is processed by us or our suppliers. We however hope that you will first contact us, so that we work with you to resolve any complaint or concern you might have; or
• you want to report a privacy or security breach in relation to your Personal Information.

Feel free to contact us for any of the above reasons or if you have any questions or requests not covered above. We will take reasonable steps to verify your identity before responding to your requests. Please note that the rights above may not be an absolute right and may be subject to certain exceptions. Your rights may differ depending on where you live or could be subject to certain legal restrictions, as applicable laws may allow or require us to deny or partially deny your request.

The type of consent we obtain or whether or not we need to obtain consent depends on the circumstances and on the applicable laws where you reside.

• Consent: When you choose to provide us with your Personal Information, for example, when you contact us with a question and provide your phone number, or when you provide your identification information to participate in our research studies, we consider that you have given us your implied consent to contact you in accordance with this Corporate Policy. In other situations, we may ask for your express consent, either by verbally consenting, signing a document, or ticking a box.
• No Consent: Sometimes it may not be possible or may be inappropriate to obtain your consent, and in those cases, we may collect, use, or disclose your Personal Information without your consent. For example: (a) if it is clearly in your interests (such as a medical emergency or a threat to your safety); (b) to comply with a warrant or other court order; (c) to investigate the breach of an agreement or applicable law; (d) to recover a debt; and/or (e) as otherwise legally required or permitted.

We protect your Personal Information in accordance with applicable laws, this Corporate Policy, and our contractual obligations wherever it is processed and whether it is held by us or by our suppliers. Accordingly, please note that, where permitted by law, we reserve the right to store and process your Personal Information outside of your province/territory and even outside of Canada. Some of these countries may have data protection laws that are different from the laws of your province/territory or Canada and, in some cases, may not be as protective.

By providing us with your Personal Information and continuing to access and/or use our Website, you consent to the transfer of your Personal Information outside of your province/territory/Canada, including to the United States, in the event that such transfer is necessary for the purposes set out in this Corporate Policy. While this information is outside of Canada, it is subject to the laws of the jurisdictions where it is stored and may need to be disclosed to governments, courts and law enforcement or regulatory authorities in that other jurisdiction, under laws of that jurisdiction.

9.1 Collected or Created Non-Personal Information: Through the use of the Tools, we or our service providers: (a) collect Non-PI about your use of our Website; and (b) may analyze and/or combine all of the information we receive, including Personal Information and information about your use of the Website, with information from other users to create the Non-PI. Please note that the aggregated/anonymized data may be retained indefinitely.

9.2 Purposes for collecting or generating the Non-PI: We use the Non-PI:

1. To better understand, customize and improve user experience with our Website and our product or service offerings;
2. To manage our advertising about our products and services based on your interest (such as providing you with Luci App advertisements);
3. To compile statistics, analyze trends and otherwise administer and improve our Website; and
4. To understand: (a) from which geographical regions users have viewed our Website; and (b) the names of other websites on which you were shown our ads.

9.3 Tools Used: Third parties, including Facebook (now Meta), may use cookies, web beacons, and other storage technologies to collect or receive information from our Website and elsewhere on the internet and use that information to provide measurement services and target ads. Please find below details about the Tools we or our suppliers use to collect Non-PI:

1. Cookies Generally: We and our service providers use “cookies” (a small text file sent by your computer each time you visit our Website and unique to your browser). When you use our Website, our servers automatically receive certain information such as your Internet Protocol address, the address of the webpages you visited that had Lucilab features, browser type and settings, the date and time of your request, how you used websites and cookie data (collectively “log data”). We use both “session” cookies (that last until you close your browser) or “persistent” cookies (that last until you and/or your browser delete them). To find out more about cookies, visit https://www.allaboutcookies.org/.
2. Website Performance and Visitor Activity Monitoring: We may use analytical tools, provided by our suppliers, to monitor the performance of our Website and visitor activity in order to tailor and improve our Website and its content. For example, we use Google Analytics, a web analytics service provided by Google Inc. (“Google“).
3. Tracking Pixels and Cookies: One way in which we deliver more meaningful advertisements related to the Luci App is through the use of tracking pixels, such as the Facebook Pixel and Google Tracker, as well as third-party cookies.
   • Tracking Pixel: A tracking pixel is a small piece of code placed on our Website. It is used to collect and share Non-PI with suppliers like Meta (formerly Facebook) and Google so that we can understand the actions users take on our Website to optimize ads, report on the success of advertising campaigns across devices and create custom audiences of Website visitors for use in our ads. The data collected is anonymous to us as the operator of our Website and we cannot use it to identify you. Users can opt-out of the collection and use of information for ad targeting by updating the account ad settings of the applicable supplier (e.g. Meta and Google) and/or following the instructions in Section 9.4(4) below.
   • Cookies: Like many companies, we may use third-party service providers to collect Non-PI and place advertisements where we think they will be most relevant to our Website users. One way we do so is by allowing network advertising companies with whom we work to place their own Tools when an individual visits our Website. This enables the network advertising company to recognize individuals who have previously visited our Website and to serve you ads based on your web browsing activity, interests and/or other information. These advertising companies may also use these types of technologies to recognize you across the devices you use, such as a mobile phone or a laptop, and serve you ads on websites you visit and applications you use.
4. Social Media Plugins: A plugin is a piece of software that adds a specific functionality or type of content to a website. For example, our Website uses social media plugins, which, when clicked, connect to Lucilab’s profile pages on various social media platforms. Our Website uses the social media plugins listed in the table below to provide you with the opportunity to access our profile pages on third-party social media platforms. By clicking on a social media plugin, you acknowledge that you will leave our Website and access a third-party social media platform, and you understand that your Personal Information may be collected, used and/or shared in accordance with such third-party social media platform’s privacy policy. For more information about the social media provider plugins used on our Website and such third-party social media provider’s privacy practices, please click on the applicable “privacy” link in the table below.
5. Device information: In addition to log data, we or our service providers may also collect information about the device you are using to access our Website (such as the type of device and browser used). This information is used to help us deliver content appropriate to your device’s capabilities. To learn more about what information your device may make available to us, please check the policies of your device manufacturer or software provider.

9.4 General information about opting out: Please find below general information on opting out as well as a table in Section 9.5 about specific opt-out methods for certain Tools. Please note that the information related to third party service providers and their privacy policies as well as the information about opting out are only provided for your convenience. We cannot guarantee its integrity or that the information is current or accurate.

1. Do Not Track: Some browsers have Do Not Track (“DNT”) features that allow you to tell a website not to track you. These features are not all uniform, and some browsers may not be set up to honor such requests. Please note, however, that Lucilab may not always be able to recognize Do Not Track signals from your browser. Options you select are browser and device specific.
2. Cookies: Tools such as “necessary” cookies are used to make our Website work and to enable its basic features (such as onsite search capabilities, location-finder tools). Since they are necessary for our Website to function, by using our Website, you agree to their use for the foregoing purpose. We may also use some “personalization” cookies to enhance your user experience on our Website (e.g., screen layouts, preferred language and to offer you personalized content that matches your interests). Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The “Help” section of your browser may tell you how to prevent your browser from accepting cookies. For more information about cookies and how to opt-out, please consult https://www.allaboutcookies.org/verify and https://www.aboutads.info/choices.
3. Device Information: You may be able to opt out in the mobile application environments by clicking on the “AppChoices” icon seen in a given advertisement. To learn more about opting out on mobile Devices, please visit the Network Advertising Initiative’s website at https://www.networkadvertising.org/mobile-choice.
4. Tracking Pixels: Please note that, unlike cookies, you cannot control the deletion of tracking pixels yourself (e.g., by deleting them from your browser cache) and information gathered through the tracking pixels, are stored on the servers of online advertisers and not in your browser. Please consult the settings of the applicable provider (e.g. Meta or Google) displaying the applicable ad to understand how to disable such tracking.

9.5 Table of Lucilab’s Tracking Tools: The table below provides additional details about some of the analytical and advertising Tools we use on our Website. For general opt out information, please see https://www.aboutads.info/choices and https://www.networkadvertising.org/mobile-choice.

• Analysis Tools: These Tools are used to track the number and type of visits to our Website and its pages / screens as well as usage patterns, in order for us to ensure that all parts of our Website are working properly. These technologies are used to provide anonymous, aggregated data on how web- and mobile-users interact with our Website.

• Advertising Tools: These Tools are used to: (a) provide you with more relevant and useful advertising and to limit how many times you see an ad; (b) help us improve the effectiveness of our advertising efforts; and/or (c) connect you with our social media profiles and accounts to keep you informed about our company and its activities. Such Non-PI can be shared with service providers or advertisers.

For your convenience, our Website may contain links to third-party websites or platforms that are not owned or operated by Lucilab. These links or any use of third-party trademarks should not be construed as an endorsement or recommendation of these third parties or their websites or platforms by Lucilab. These other websites and platforms are not subject to this Corporate Policy and have their own privacy policies and terms of use. We have no control over these websites and platforms and assume no responsibility for the ways in which the organizations that operate these other websites and platforms collect, use, disclose, protect and otherwise treat your Personal Information. Your use of these links will be at your own risk.

Our Website links to certain social media providers (e.g., Meta and LinkedIn) where we have our company profile or account. If you choose to post content or otherwise interact, we will be able to view such interactions. Information collected through third-party apps, tools, widgets, and plug-ins (such as relating to your use of a Meta “Like” button) is collected directly by the providers of these features. This information is subject to the privacy policies of those providers of the features, and we are not responsible for those providers’ information practices.

We do not intentionally collect or use any Personal Information from minors. We do not knowingly allow children to communicate with us or use or order any of our Website services. If you become aware that your child is using or has used our Website without your consent or that someone is using or has used the Website on your child’s behalf without your consent, please contact us. If we learn that we have collected any Personal Information from a child without verification of parental consent, we will delete that information from our database as quickly as possible.

Lucilab reserves the right to modify this Corporate Policy at any time. Any modifications to the Corporate Policy will be posted on this page. Please review this Corporate Policy from time to time to ensure that you are aware of any such modifications. Your continued use of the Website following the posting of any modifications or updates to the Corporate Policy constitutes your acceptance of those changes.

You can write to us by writing us at [email protected] or contacting the Chief Privacy Officer at:

Chief Privacy Officer
160 Saint-Viateur Street E, Suite 801, Montreal (QC) H2T 1A8
[email protected]
1-844-LUCILAB (1 844 582-4522)